CPSIA Compliance for Custom Printed Kids' Apparel

If a shirt is printed for children 12 and under, federal law treats it as a children's product — and the shop that printed it, not the company that made the blank, is the manufacturer of that product. That one sentence is the whole topic, and almost nobody in the decorated apparel business says it out loud. This page is the plain-English version for buyers in Nevada and anyone else who has to sign off on an order of kids' shirts.

We are a screen printing, embroidery and DTF shop in Yerington, Nevada. We print youth shirts for schools, booster clubs, youth leagues, daycares, 4-H chapters, church groups and family businesses, and we get asked about this maybe twice a year — which is roughly two thousand times less often than it should come up. Below is what the law actually says, what it does not say, what is genuinely unsettled, and what to require of any decorator before you hand them a purchase order.

This is general information about federal regulations, not legal advice. We are printers, not lawyers. Where something is unresolved we say so instead of guessing, and every rule cited here can be read for free on eCFR.

The short version

• Children's product = designed or intended primarily for children 12 years of age or younger. Twelve is included. Youth sizing plus a school or youth-league logo puts an order squarely inside the definition.
• The decorator is the finished-product certifier. Under 16 CFR 1110.7(b), for a product manufactured in the United States, "the manufacturer is the finished product certifier." Printing on a blank makes a new finished product. The blank supplier certified a blank.
• The blank's certificate does not transfer. It is a component-part document you may lean on under 16 CFR part 1109 — which is genuinely useful — not a substitute for a certificate on the decorated garment.
• A Children's Product Certificate has seven required elements, no required format, no fee, and is filed with nobody. It has to travel with the shipment and be producible within 24 hours if CPSC asks. Records are kept five years.
• The blank tee is usually relieved of lead testing. The print is not. The textile determination at 16 CFR 1500.91(d)(7) covers dyed natural and manufactured fibers; the printing-ink determination at (d)(6) expressly excludes "screen prints, transfers, decals, or other prints."
• Phthalates do not reach an ordinary youth t-shirt. 16 CFR part 1307 covers children's toys and child care articles. It absolutely does reach bibs, burp cloths and sleep items — which decorators print all the time.
• Tracking labels have to be permanent. CPSC says plainly that hangtags and adhesive labels are not.
• Three orders can go wrong fast: youth hoodies with neck drawstrings, anything that is legally sleepwear, and baby items that count as child care articles.

Everything below expands on those points, and each one has its own detailed article linked at the bottom.

Is your order a children's product?

The definition comes from the Consumer Product Safety Improvement Act and is interpreted at 16 CFR part 1200: a consumer product "designed or intended primarily for children 12 years of age or younger." CPSC weighs four factors:

1. A statement by the manufacturer about intended use, including a label, if that statement is reasonable.
2. Whether the product is represented in its packaging, display, promotion or advertising as appropriate for children 12 and under.
3. Whether consumers commonly recognize it as intended for children 12 and under.
4. The CPSC Age Determination Guidelines (most recent edition).

A youth-sized tee with an elementary school logo hits factors one, two and three at once. It is a children's product, and 16 CFR 1200.2 says items "specifically sized for children or marketed to appeal primarily to children remain classified as children's products regardless of broader appeal" — so the fact that a parent might wear a Youth XL does not get the order out from under it.

An adult-sized shirt that a thirteen-year-old buys is not a children's product. Two independent reasons: the child is outside the covered age band, and a product designed primarily for consumers over 12 is a general use product even when children also use it. Incidental use by a child does not convert a general use product.

The real-world wrinkle is the size run. Most school and league orders span Youth S through Adult 3XL on one purchase order. The youth portion is a children's product. The adult portion is not. They can be on the same invoice and still be two different regulatory animals, which is why a decorator should be splitting them in the job file rather than treating the order as one undifferentiated pile of shirts.

Where does youth stop? Sizes 14 and 16 are usually worn by teenagers, and it is tempting to argue they fall outside "12 and younger." CPSC has not drawn a bright line at a size number for t-shirts, and we are not going to invent one. The conservative practice, and ours, is to treat the whole youth size run as a children's product. It costs nothing to be careful and it removes the argument.

Who is responsible — and why it is the printer

This is the part of the topic that decorators dislike, so it gets handled directly.

CPSC publishes free sample Children's Product Certificates to show businesses what one looks like. The sample it published for clothing is issued by a screen printer. The product is a "baby bodysuit garment with screen printed decoration," and the certifier on the face of the certificate is a fictional shop called Mama Mama Screenprinters in Boston. The annotations on that page note that suppliers of blank garments or screen-printing ink may have performed testing on their individual components, and that the manufacturer may rely on those component certifications while still issuing its own certificate for the finished product.

When the federal agency that enforces the law picks one worked example for apparel, and the example it picks is a screen printer certifying a printed bodysuit, the question of who certifies a printed kids' shirt is not really open.

Two more supports point the same way. CPSC's guide to federal safety laws for promotional products states that importers and manufacturers of finished children's products are responsible for complying with children's product regulations, and that a distributor who — at a client's direction — directs the final production of a blank general use product into a children's product is the responsible party. And the governing rule is blunt: 16 CFR 1110.7(b), for a finished product manufactured in the United States, "the manufacturer is the finished product certifier," with the private labeler taking that role if the product is privately labeled.

The logic is not complicated. Your blank supplier certified a blank garment. The thing that leaves our building is a different product — different composition, different appearance, different identity, sold under someone else's name. Somebody has to certify that, and the only party that knows what ink went on which blank on what date is the shop that printed it.

Embroidery is not exempt from this reasoning. The promotional-products guidance turns on performing "an operation that transforms the garment in any way." Embroidery adds thread and needle penetrations. We have found no CPSC document that singles embroidery out, in either direction, and we are not going to claim one exists.

If you are a school, a district, a league or a brand buying decorated kids' apparel, the practical consequence is good news: there is a defense in the statute for a distributor or retailer who holds a proper certificate. Section 19(b) of the Consumer Product Safety Act protects good-faith reliance on a certificate you actually have. That is exactly why you should be asking for one, and why a decorator who cannot produce one is a commercial problem for you before it is ever a legal one.

Read the full breakdown: who is the manufacturer of a printed kids' shirt →

The rules that actually apply to a decorated youth garment

CPSIA is often discussed as if it were a single requirement. It is a stack of separate rules, and only some of them touch a printed shirt.

Total lead content — 15 U.S.C. 1278a, limit 100 ppm

Applies to accessible component parts of children's products. The base fabric is normally relieved of testing by the textile determination at 16 CFR 1500.91(d)(7), which covers natural and manufactured fibers "dyed or undyed." Dyeing does not break that relief. The print is a different story — see the ink section below.

Lead in paint and similar surface coatings — 16 CFR part 1303, limit 0.009 percent (90 ppm)

CPSC's own sample certificate for a screen-printed baby bodysuit lists part 1303 as an applicable rule. Whether a cured ink film is legally "paint" is the genuinely unsettled question on this whole subject, and it gets its own section further down.

Flammability of clothing textiles — 16 CFR part 1610

Applies to wearing apparel generally. Section 1610.1(d) exempts from testing "plain surface fabrics, regardless of fiber content, weighing 2.6 ounces per square yard or more," and all fabrics of any weight made entirely from acrylic, modacrylic, nylon, olefin, polyester or wool. A 5.3-ounce cotton tee clears the weight exemption comfortably; a 100 percent polyester performance tee clears on fiber content. Fleece and other raised-surface goods do not get the plain-surface exemption and have to be looked at on their own terms.

Phthalates — 16 CFR part 1307, limit 0.1 percent

Here is where a lot of published industry advice is simply overbroad. Part 1307 reaches children's toys and child care articles — items designed to facilitate sleep or feeding for children three and under, or to help with sucking or teething. An ordinary youth t-shirt is neither, and the phthalate rule does not apply to it.

But plastisol ink is plasticized PVC by construction. The moment a shop prints a bib, a burp cloth, a swaddle, a sleep sack or a plush item, part 1307 is squarely in play. Baby-shower and daycare work is where this bites, and it is bitten quietly for years.

Small parts — 16 CFR part 1501

Applies to articles for children under three. Relevant when infant items get snaps, appliqués or attached embellishments. Note that small parts is one of the rules that small-batch relief never covers.

Children's upper outerwear drawstrings — 16 CFR 1120.3(b)

Hoodies and sweatshirts are core decorator product, which makes this the most likely rule for a small shop to run into. Children's upper outerwear in sizes 2T to 16 with drawstrings not conforming to ASTM F1816-97 is on the substantial product hazard list: hood and neck drawstrings prohibited through size 12, waist and bottom drawstrings through size 16. A retailer paid a $1.5 million civil penalty in 2012 over children's outerwear with neck drawstrings. Full article on drawstrings →

Children's sleepwear — 16 CFR part 1615 (sizes 0 to 6X) or part 1616 (sizes 7 to 14)

A completely different and much stricter regime than part 1610, and CPSC's sample clothing certificate says so on its face. If the item is sleepwear, 1615 or 1616 replaces 1610. What makes this a decorator problem rather than a garment-maker problem is that decoration is one of the factors CPSC weighs in deciding whether a garment is sleepwear at all. Full article on the sleepwear trap →

The blank is relieved. The print is not.

This is the single most misunderstood point in the trade, including by shops that mean well.

The lead-content rule comes with a list of materials CPSC has determined do not exceed the limit, at 16 CFR 1500.91(d). Textiles are on that list — natural fibers and manufactured fibers, "dyed or undyed." So a plain dyed cotton or polyester blank does not need lead testing. Good.

But read the parenthetical. The determination excludes "any textiles that contain treatments or applications that do not consist entirely of dyes." And the printing-ink entry, at (d)(6), covers "CMYK process printing inks" while expressly excluding "spot colors, other inks that are not used in CMYK process, inks that do not become part of the substrate under 16 CFR part 1303, and inks used in after-treatment applications, including screen prints, transfers, decals, or other prints."

The rulemaking record explains why. Dyes dissolve and bond into the fiber. Pigments are insoluble and sit in a binder on the surface. When CPSC wrote the determinations in 2009 it noted that screen printing spans UV, water-based, plastisol and solvent systems, and that it "cannot determine that all screen printing inks do not contain lead." Spot colors were excluded because they could contain leaded pigments, verifiable only by testing.

So: the blank tee is relieved of lead testing. The moment you print on it, the printed area is outside the determination. Almost all garment decoration — plastisol spot colors, water-based, discharge, transfers, decals, and by the plain text of the rule "other prints" — needs test data behind it. Not necessarily your test data; see component-part testing below. But data.

Other things that break the textile determination in a decorator's world, which is a list worth knowing if you buy blanks: heat-transfer neck labels and tagless tag prints, glitter and foil, rhinestones and their adhesive, flock, puff and stretch additives, and chemically applied water-repellent or antimicrobial finishes. Whether a chemically applied moisture-wicking finish counts as a disqualifying treatment is not something CPSC has answered; fiber-engineered wicking is a fiber property, an applied finish arguably is a treatment. Ask the blank supplier for the finish chemistry and keep the answer.

A determination relieves testing. It does not relieve the limit, and it does not relieve the certificate. The garment still has to comply with 100 ppm; you simply certify on the basis of the determination instead of a lab report. Lots of shops hear "exempt" and conclude "no paperwork." That is the opposite of what the rule says.

The rule that makes this affordable: component-part testing

If every decorated kids' order required destructive lab testing of finished garments, no small shop could do youth work at all. 16 CFR part 1109 is the rule that prevents that outcome, and it is the most important thing a small printer can understand about this topic.

Part 1109 lets the finished-product certifier rely on testing performed on component parts — including testing arranged and paid for by somebody else. Your ink maker tests the ink. Your blank supplier documents the fabric. You assemble those into a certificate for the garment. Section 1109.11 is helpfully practical about coatings: the substrate the lab tests "need not be of the same material" as the finished product, and the coating may be submitted "in liquid form or in the form of a dried film" — which is exactly how ink manufacturers test.

The cost consequence matters: a lab test on an ink is a one-time cost spread across every job ever printed with that ink. It is not a per-order expense. That is the entire point of part 1109 and the reason a 48-piece school order is economically possible.

Reliance is conditional, though, and here is where it breaks in practice:

• Wrong document. A supplier "compliance statement," an SDS, an OEKO-TEX certificate or a marketing claim is not a third-party test report to a children's product safety rule. OEKO-TEX is a private ecolabel with a different scope. It is a fine thing to have and it is not CPSIA certification.
• Not identical in all material respects. You hold a report for Ink Line A, Color X, and the press ran Color Y. Reliance evaporates.
• No traceability. You cannot tie the ink lot and blank lot used on job 4471 back to the report. Part 1109 requires lot-level traceability, which in practice means a job record, not a memory.
• Your own process changed the outcome. This is the big one. A reducer, a curable reducer, a soft-hand extender, a puff or stretch additive, or a color you mixed yourself from base plus pigment was never in the tested formulation. Section 1109.5(b) requires that your process not "add or result in a prohibited level of a chemical." Mixing your own colors voids reliance on the finished-color test.
• Stale documents. Periodic testing under 16 CFR 1107.21 applies to the component too. A five-year-old report standing behind current production is a weak position.
• Rules that depend on construction. Component reliance handles chemical rules well. It does not automatically cover flammability behavior of the printed assembly, drawstring conformance, or small parts on the finished garment.
• The blank's own components. Rib collars, thread, snaps, zipper pulls and tagless neck prints are separate components. CPSC's promotional-products guidance specifically flags metal and plastic pieces such as zipper pulls.

Full article on component-part testing and the seven ways reliance fails →

The certificate itself

A Children's Product Certificate sounds like a bureaucratic ordeal. It is a one-page document with seven required pieces of information, and building it is a template exercise you do once.

16 CFR 1110.11(a) requires: product identification sufficient to identify the product (a job number plus style and color works as an "alternate identifier"); each rule certified to, cited separately; the identity of the certifier with full contact details; a contact for test records, which "can be a position title, provided that the position is always staffed"; the date and place of manufacture, month and year at a minimum — your shop, your print date; the dates and places of testing; and identification of the CPSC-accepted third-party laboratory, with the required attestation.

Then the operational facts, which are the ones that surprise people:

• No format is required. CPSC: no specific template need be followed as long as the seven elements are present and accurate.
• Nothing is filed. For a domestic decorator there is no submission and no fee. Importers of finished children's products have a separate electronic filing obligation at entry; a shop buying blanks from a US distributor is not the importer of those blanks.
• It has to accompany the shipment. Section 1110.13(a). In the box, or as a stable URL on the packing slip. Electronic certificates are expressly permitted.
• It has to be furnished to distributors and retailers under 1110.13(b), if you are selling to one rather than to the end user.
• Twenty-four hours. You must be able to produce it within a day of a CPSC or Customs request.
• Five years of records under 16 CFR 1107.26 — the certificate, the component documentation, the traceability linking the job to the lots, and your due-care records.
• A new certificate on a material change under 16 CFR 1107.23: new ink line, new color, new blank supplier or style, new fabric blend, new decoration method.

Full article, including a fill-in-the-blanks CPC layout →

Tracking labels: hangtags do not count

Separate requirement, separate statute — section 14(a)(5) of the Consumer Product Safety Act, 15 U.S.C. 2063(a)(5). There is no CFR part implementing it; CPSC guidance is the operative source.

A children's product needs a permanent, distinguishing mark that, to the extent practicable, carries the name of the manufacturer or private labeler, the location and date of production, detailed information on the manufacturing process such as a batch or run number, and anything else that helps identify the specific source. It must be visible and legible, and the statute asks for it on both the product and its packaging.

CPSC is explicit that "hangtags and adhesive labels are not permanent." For textiles, the label must be durable enough to last the anticipated lifespan of the product when the care instructions are followed. In practice that means sewn-in, heat-applied, or a printed tagless label — something that survives the garment's wash life. A hang tag or a sticker does not satisfy the product-marking requirement.

One genuinely useful wrinkle for custom work: an industry fact sheet from the trade association notes that where only a few shirts are printed with a unique design, that print is itself a distinguishing mark satisfying the batch element. A one-off design for one school in one production run is the batch identifier. That is an industry reading rather than a CPSC statement, and it addresses only the batch element — the manufacturer name and the production date and place still have to appear somewhere permanent.

Open question, stated as open: we have found no CPSC guidance on whether a decorator may rely on the blank maker's existing sewn-in label to satisfy this, or must add its own. The logic of the rest of this page suggests the decorator's own name and date have to appear, since the blank maker's label identifies the wrong manufacturer and the wrong date. The conservative practice — add your own permanent label — is cheap and defensible. Full article on tracking labels →

The honest unresolved question

Most pages about this subject are written to sound authoritative. Here is the place where nobody actually knows, and where you should distrust anyone who tells you they do.

Is a cured screen print legally "paint" under the lead-in-paint rule?

The argument that it is not: 16 CFR 1303.2(b) defines paint and similar surface coatings, then says the term "does not include printing inks or those materials which actually become a part of the substrate."

The arguments that it is: 16 CFR 1500.91(d)(6) carves out of the ink determination "inks that do not become part of the substrate under 16 CFR part 1303" — language that only makes sense if CPSC contemplates that some printing inks are governed by part 1303. And plastisol is the archetype of an ink that does not become part of the substrate: it cures into a discrete film sitting on top of the fabric, which is not what a dye does. On top of which, CPSC's own sample certificate for a screen-printed baby bodysuit lists part 1303 as an applicable rule.

We searched for a CPSC guidance document, staff opinion or rulemaking preamble that squarely holds cured plastisol on a garment is, or is not, paint under part 1303. We did not find one. A FOIA'd CPSC staff document on lead paint testing addresses only the mechanics of separating a coating from its substrate and says nothing about textile prints.

So the practical position — ours, and what we would tell any shop that asked — is to treat cured plastisol and similar films as a surface coating subject to the 90 ppm lead-in-paint limit, because that is what CPSC's own worked example does. The downside of being careful is a line item on a test report. The downside of being wrong the other way is an uncertified children's product, and part 1303 happens to be one of the rules that small-batch relief never excuses. Full article on the paint question →

DTF is even less settled. Direct-to-film postdates the 2009 determinations entirely. On the text of the rule a DTF transfer is plainly an after-treatment application and sits outside the ink determination, and the cured ink-plus-adhesive film sits on the fabric surface like plastisol, so the same analysis applies with at least equal force. The hot-melt adhesive powder is a separate component part with no determination covering it. We found no CPSC, trade-association or laboratory guidance addressing DTF under CPSIA at all. Anyone who tells you DTF is cleared for children's products is telling you what they hope, not what they know.

What we do, and what we will not claim

The same rule we apply to flame-resistant workwear applies here: we will tell you what we actually do and we will not dress it up.

• We only run branded, documented ink. Our production inks are phthalate-free and lead-free lines from Rutland, Wilflex, International Coatings, Matsui and CCI. No unbranded, untested or out-of-date ink goes on a job, and specialty products are held to the same standard.
• We keep a batch record on children's work that links the specific ink formulations and blank garments used in that production run, so the traceability part 1109 asks for exists on paper rather than in someone's head.
• We can apply permanent tracking labels as neck tags or integrated into the garment label, carrying our shop identification, production date and a batch number that ties back to our records.
• We ask the blank supplier for the documentation — fiber content, weight and surface type, absence of non-dye treatments, component documentation for thread and trim, and lot numbers.
• We hold the test documentation, and we will send it to you. We obtain third-party test documentation for the ink lines and the blanks used on children’s work and supply it on request. That is component-part documentation under 16 CFR part 1109 — the mechanism the rule is built around — not a marketing letter, not a safety data sheet and not an ecolabel.
• We issue the Children’s Product Certificate. As the manufacturer of the finished product we are the party that certifies it, and we do. Ask for it when you place a job with youth sizes and it ships with the goods, citing the specific rules — 15 U.S.C. 1278a, 16 CFR part 1303, 16 CFR part 1610 — rather than the empty phrase “CPSIA compliant.” We also put the compliance question on the order in writing before we print: what the item is, which rules apply, and what the certificate will cite.
• We do not apply DTF to items intended for infants and toddlers for the reason stated above — nobody has published a position, and we would rather use a process we can document.
• We will never tell you our decoration is "CPSIA certified" as a slogan. There is no such badge. There are specific rules, specific test data and a specific certificate, and anyone selling you the phrase without the paperwork is selling you a feeling.

If your district, league or brand has a procurement standard that requires specific test data or a certificate in a specific form, send it to us with the quote request. It is a much better conversation to have before the screens are burned.

Buyer's checklist: what to require from any decorator

Use this on us, and on everyone else you quote. A shop that cannot answer these is not necessarily breaking the law — but it is guessing, and you are the one holding the shirts.

1. "Is this order a children's product, and which sizes?" A shop that has never thought about the size-run split will tell you the whole order is the same thing.
2. "Who is issuing the Children's Product Certificate?" If the answer is "the blank company already has one," they have the rule backwards.
3. "What will the certificate cite?" You are looking for specific rules — 15 U.S.C. 1278a, 16 CFR part 1303, 16 CFR part 1610 — not the words "CPSIA compliant."
4. "Do you have a third-party test report for the specific ink line and colors on my job?" Not an SDS. Not a compliance letter. Not OEKO-TEX.
5. "Are you mixing my Pantone from base and pigment?" If yes, ask what test data covers the mixed color.
6. "How do you tie my job back to the ink lot and blank lot?" The answer should describe a record, not a habit.
7. "What permanent tracking label goes on these, and what does it say?" If the answer is a hang tag, that is not what the statute asks for.
8. "If these are hoodies, do they have hood or neck drawstrings?" Sizes through 12, prohibited. Ask before the art is approved.
9. "Are any of these items sleepwear, bibs, burp cloths or sleep items?" Different rules, and the wrong answer here is the expensive one.
10. "Will the certificate ship with the order?" It is supposed to.

Longer version written for schools, districts and leagues →

Kids' and youth garments we print

Youth blanks are not just adult blanks scaled down. Sizing runs differently, fabric weights are lighter, the print area is smaller so artwork has to be redrawn rather than shrunk, and a few styles carry construction details — drawcords, snaps, tagless neck prints — that matter for the reasons above.

These are the youth and toddler styles we keep in regular rotation. Prices are wholesale-plus on our published pricing basis, decoration quoted separately.

• Youth tees. Gildan 5000B heavy cotton and 64000B softstyle, Bella+Canvas 3001Y, Next Level 3310 and 3312 CVC, Comfort Colors 9018 garment-dyed, Port & Company PC54Y.
• Toddler and infant. Bella+Canvas 3001T toddler tee, Port & Company CAR54T, Rabbit Skins 3321 fine jersey tee and 4400 infant bodysuit.
• Youth fleece. Gildan 18500B hooded sweatshirt, District DT6000Y, JERZEES 996YR and Independent SS4001Y — the last two built without a hood drawcord, which is the correct choice for a youth hoodie order and one reason we default to them.
• Youth performance. Sport-Tek YST350 for leagues and PE programs.
• Youth headwear. Flexfit 6277Y fitted.

Browse youth and toddler blanks → · Youth sizing and team apparel buyer's guide →

Minimums and turnaround are the same as everything else we do: 48 pieces per design on screen printing, no minimum on embroidery or DTF, 10 to 14 business days from an approved proof. We are in rural Nevada, which is why the number is honest rather than optimistic.

What actually happens when this goes wrong

The statute provides for civil penalties in the six figures per violation and eight figures for a related series of violations, adjusted annually for inflation, plus criminal exposure for knowing and willful violations. We are deliberately not printing a specific dollar figure, because the figures are adjusted and most of the numbers circulating online are out of date.

For a small shop and its customers, the realistic consequences are more mundane and much more likely:

• A recall. Public notice, customer notification, retrieval, refund or replacement. On a 200-piece school order the cost and the embarrassment dwarf any penalty exposure.
• A reporting duty you did not know you had. Section 15(b) of the Consumer Product Safety Act requires manufacturers, distributors and retailers to report to CPSC immediately — within 24 hours — after obtaining information reasonably supporting the conclusion that a product contains a defect that could create a substantial product hazard. Failure to report is itself one of the most common bases for penalties.
• Losing the account. School districts, national brands and online marketplaces increasingly require a certificate as a condition of purchase. This is the outcome that actually happens: not a federal enforcement action, just a procurement officer moving on to a vendor who has the paperwork.

Note also that CPSC's penalty factors expressly include the appropriateness of a penalty in relation to the size of the business and its ability to pay. Being small mitigates. It does not immunize.

The full series

Each of these goes deeper than the summary above, with the rule text and the citations.

• Who is the manufacturer of a printed kids' shirt? — why CPSC's own worked example is a screen printer, and why the blank supplier's certificate does not transfer.
• What goes on a Children's Product Certificate — all seven required elements with a fill-in layout, and the operational rules nobody explains.
• Component-part testing — the rule that makes kids' work affordable, and the seven ways reliance on it fails.
• Tracking labels on decorated kids' apparel — what permanent means, what goes on the label, and the open question about the blank's own tag.
• Drawstrings — the rule most likely to catch a decorator, and how to check a hoodie before you print it.
• The sleepwear trap — why decoration itself helps decide whether a garment is legally sleepwear.
• Is a screen print "paint"? — the genuinely unresolved question, laid out from both sides.
• What a school, league or daycare should require — the buyer-side version, written to be forwarded to a vendor.
• CPSIA screen printing overview — our original guide to printing children's apparel.
• School spirit wear and booster club shirts — the ordering, fundraising and calendar side.

Frequently asked questions

Will you give us a Children’s Product Certificate?

Yes. As the manufacturer of the finished product we are the party that certifies it under 16 CFR 1110.7(b). Ask for the certificate when you place a job that includes youth sizes and it ships with the goods, citing the specific rules that apply rather than the phrase “CPSIA compliant.” We can also supply the underlying third-party test documentation for the ink lines and blanks used on your run.

What counts as a children's product?

A consumer product designed or intended primarily for children 12 years of age or younger, interpreted at 16 CFR part 1200. Twelve is included, not excluded. CPSC weighs four factors: the manufacturer's statement of intended use, how the product is represented in packaging and advertising, how consumers commonly recognize it, and the CPSC Age Determination Guidelines. A youth-sized shirt carrying an elementary school or youth-league logo satisfies several of them at once.

Does my blank supplier's certificate cover my printed shirts?

No. The blank supplier certified a blank garment; a decorated garment is a different finished product. Under 16 CFR 1110.7(b), for a product manufactured in the United States the manufacturer is the finished-product certifier. The blank supplier's document is a component-part record you may rely on under 16 CFR part 1109, which is genuinely valuable, but it is not a certificate for the decorated garment.

Is the screen printer really the manufacturer?

For a garment printed in the United States, yes. CPSC's own published sample Children's Product Certificate for clothing is issued by a screen printer for a baby bodysuit with screen printed decoration, and its promotional-products guidance states that a party who directs the final production of a blank general use product into a children's product is the responsible party. Embroidery follows the same reasoning, since the guidance turns on performing an operation that transforms the garment.

Do youth t-shirts have to be tested for phthalates?

No. 16 CFR part 1307 reaches children's toys and child care articles — items designed to facilitate sleep or feeding for children three and under, or to help with sucking or teething. An ordinary youth t-shirt is neither. The rule does apply to bibs, burp cloths, swaddles and sleep items, which decorators print regularly, and plastisol ink is plasticized PVC, so those jobs need real attention.

Is the blank fabric exempt from lead testing?

Usually yes, and the print usually is not. 16 CFR 1500.91(d)(7) determines that textiles of natural or manufactured fibers, dyed or undyed, do not exceed the lead limit, so dyeing does not break the relief. But the determination excludes textiles containing treatments or applications that are not entirely dyes, and the printing-ink determination at (d)(6) expressly excludes screen prints, transfers, decals and other prints. A determination also relieves only testing — the 100 ppm limit and the certificate still apply.

Does every kids' order need a lab test?

Usually not a test of your finished garment. 16 CFR part 1109 lets the finished-product certifier rely on component-part testing performed and paid for by others — typically the ink maker's third-party report plus the blank supplier's documentation. A lab test on an ink is a one-time cost spread across every job printed with that ink. New testing becomes necessary when the ink supplier cannot produce a report for your color, when colors are mixed in-house or additives are used, when the design includes glitter, foil, rhinestones or flock, or when the item is a toy or child care article.

Where is a Children's Product Certificate filed?

Nowhere, for a domestic decorator. There is no submission and no fee. The certificate must accompany each shipment under 16 CFR 1110.13(a), be furnished to any distributor or retailer under 1110.13(b), and be producible within 24 hours of a CPSC or Customs request. Records are kept five years under 16 CFR 1107.26. Importers of finished children's products have a separate electronic filing obligation at entry.

Can a hang tag be the tracking label?

No. CPSC states that hangtags and adhesive labels are not permanent. A tracking label on apparel needs to be sewn in, heat applied or printed as a tagless label, durable enough to last the garment's anticipated lifespan under normal care. It should carry the manufacturer's name, the location and date of production, and a batch or run number, and the statute asks for marking on the packaging as well as the product.

Can you print youth hoodies with drawstrings?

Not with hood or neck drawstrings in children's sizes. 16 CFR 1120.3(b) places children's upper outerwear in sizes 2T to 16 with drawstrings not conforming to ASTM F1816-97 on the substantial product hazard list: hood and neck drawstrings are prohibited through size 12 and waist or bottom drawstrings through size 16. We default to youth fleece styles built without a hood drawcord, and we check the style before art is approved.

Can you print children's pajamas?

Children's sleepwear falls under 16 CFR part 1615 for sizes 0 to 6X or part 1616 for sizes 7 to 14 instead of the general apparel flammability standard, and those rules are far stricter. Decoration is itself one of the factors CPSC weighs in deciding whether a garment is sleepwear. Talk to us before assuming a soft loungewear set can be printed as ordinary apparel.

Is DTF safe for children's apparel?

Nobody has published a position. Direct-to-film postdates the 2009 lead determinations, a DTF transfer is plainly an after-treatment application outside the printing-ink determination, and the hot-melt adhesive powder is a separate component part with no determination covering it. We found no CPSC, trade-association or laboratory guidance on DTF under CPSIA. We do not apply DTF to infant and toddler items for that reason, and we would treat any claim that DTF is cleared for children's products with suspicion.

What is the minimum order for custom kids' shirts?

Screen printing is 48 pieces per design. Embroidery and DTF have no minimum, so a single youth shirt or a dozen toddler tees can be done. Standard turnaround is 10 to 14 business days from an approved proof.

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